Protocol Proposed to Netherlands-U.S. Tax Treaty

President Bush sent a Message to the U.S. Senate transmitting for advice and consent to ratification a Protocol that would, if adopted, modify the Netherlands-U.S. Tax Treaty. Among its many provisions is one that seems, to my non-tax mind, intended to avoid double taxation of income derived from shipping and air transport activities within the other nation’s territory for “qualified persons”. While written in the usual cryptic language of taxation, the provision may be designed to avoid implications of a recent U.S. Internal Revenue Service (IRS) regulation. You may wish to seek advice of an expert tax lawyer. (HK Law)